The SEC Office of Investor Education and Advocacy issued an Investor Bulletin to inform investors about the features and risks of structured notes. The SEC explained that structured notes are issued by financial institutions whose returns are based on, among other things, other securities and a broad range of types of commodities, including various indices. Common types of structured notes sold to individual investors include principal protected notes, reverse convertible notes, enhanced participation or leveraged notes, and hybrid notes that combine multiple characteristics. The SEC noted

The SEC extended previous no-action relief provided to broker-dealers in 2013 under Exchange Act Rule 17a-8 ("Financial Recordkeeping and Reporting of Currency and Foreign Transactions") if a broker-dealer relies on a registered investment adviser to perform some or all of its customer identification program obligations. In February 2004, the SEC Division of Trading and Markets (the "Division"), in consultation with the Financial Crimes Enforcement Network, issued a letter stating it would not recommend enforcement action to the SEC if a broker-dealer treated a registered investment adviser as

The SEC issued an exemption from Exchange Act Rule 14e-5 ("Prohibiting Purchases Outside of a Tender Offier") for iShares Commodities Select Strategy ETF. The exemption permits a Market Participant Covered Person (as defined in the incoming letter) participating in a tender offer for a security in which the Fund invests to: (i) redeem Shares in Creation Unit size aggregations for Fund Securities; (ii) engage in secondary market transactions in Shares after the first public announcement, given certain conditions; (iii) make purchases or arrangements to purchase subject securities in the

SIFMA submitted comments to the SEC regarding the proposed national market system ("NMS") plan to implement a tick size pilot, filed with the SEC by U.S. equity securities exchanges and FINRA. SIFMA stated that while it supported a pilot program exploring how a wider tick size might benefit small cap issuers, it expressed concern regarding a pilot that would prohibit trading between the wider quoting increments. Additionally, according to SIFMA, for a pilot program to be successful it must establish clearly stated metrics for use in evaluating the results of the pilot and determining whether

The IRS plans to issue new proposed regulations in 2015 to deal with the tax treatment of swaps with contingent nonperiodic payment swaps. The IRS and Treasury are also expected to issue "in the very near term" final regulations under Section 871(m) of the Internal Revenue Code which requires taxes to be withheld on payments (or deemed payments) to non-U.S. persons of dividend equivalents on certain equity swaps and equity derivatives referencing U.S. stocks. The final regulations were originally targeted for issuance by the end of 2014 with an effective date of January 1, 2016, to allow